PRIVACY POLICY

For Streebl Ltd. (“The Company”, “we”, “us”) the protection of your personal information is top priority. With this privacy notice, we aim to inform you what personal data we collect from users of the https://streebl.com website (referred to as the “website”) and the Streebl mobile application (referred to as the “mobile app”), why we collect it, with whom we share this information and what your rights are in connection with the processing of your data.

 

Before you start using the Website and/or mobile app, you should carefully read and familiarize yourself with this notice, agreeing explicitly with it before registering and installing the mobile app. We reserve the right to update this notice at any time by informing you promptly.

 

Please read this Privacy Policy carefully and inform yourself how your personal data is being used and the ways you can protect its privacy.

 

  1. Our Data

 

“Streebl” Ltd. is registered in the Commercial Register at the Registry Agency with UIC 20923332 and address: Sofia, 49 Chataldzha Str., fl.3, apt.7. According to the General Regulation Protection Of Personal Data (GDPR), we act as controller of the personal data when we collect, store and use your personal data to provide you with the ordered mobile application services to unlock and lock bicycle at Streebl bicycle stations on the territory of the Republic of Bulgaria.

 

Streebl Ltd. is responsible for providing the required by law information and processing of the requests of the data subjects provided for the GDPR and described in this notice for users on the territory of the Republic of Bulgaria. We have a Data Protection Officer who can be contacted for questions about this privacy notice or you can ask about your rights as data subjects by e-mail: [email protected].

 

  1. How and what personal data do we collect?

 

We collect personal data directly from you (e.g. upon registration), through our interaction with you in providing our services and through the mobile app you use.The personal data we collect about you includes the following categories:

 

  • Identifying data: first name, surname;
  • Contact details: phone number; place of residence (country, city); e-mail address;
  • Data on the use of bicycle stands: location of the station used, date, time and duration of use of stand, moment of unlocking and locking the stand, information that allows determining the parking time of the bicycle.
  • Data from our communication with you: correspondence regarding requests for assistance, questions, complaints, opinions in case you have evaluated our services or other users, etc.
  • IT management data: IP address, operating system, communication data, logs and other meta-data from. The use of the application, etc.also obtain location data on the mobile device while using the mobile app in order to be notified of the nearest stations nearby. You can change your mobile device settings at any time.

 

  1. Basis and purposes of data processing

 

By filling in the personal contact details, the user authorizes us to use this information to communicate with them in connection with the Services we provide. Receiving the contact details does not oblige us to make such contact.

 

  • Registration and enrollment of customers;
  • Conclusion, administrating and execution of contracts;
  • Communication with the customer;
  • Compliance with legal requirements e.g. accountability, accurate identification of customers,
  • Protection and control of the assets held by the company, our legitimate interests and rights and ensuring your security and security of third parties;

 

On the basis of our legitimate interest in business development, anonymized aggregated data on the customer services may be used for statistical analysis and marketing research purposes after complete removal of your identifying personal data.

 

Subject to your explicit consent, we may also use your contact details to send marketing messages for our services or suggestions. You can withdraw your consent at any time and refuse to receive newsletters by clicking on the “unsubscribe” link. If you agree to process your data for direct marketing purposes, we ask you to note your consent to the processing of personal data for direct marketing purposes at the time of registration or to log in to your personal account and choose a newsletter feature.

 

  1. Method of collection of personal data

 

Each user provides their data personally by entering or providing it in the Mobile App.

 

Users are not allowed to enter personal data of third parties, users are not allowed to register personal data of third parties using a third-party email address without the express permission of the third party. Our team does not monitor or control the content entered by the users. It is the responsibility of the user to ensure that the actions for the provision of personal data carried out by the user with our Mobile App complies with the requirements of the General RegulationData Protection Authority (GDPR).

 

  1. What if you don’t provide us with the data we require?

 

When registering in our system, it will explicitly indicate the data  required for the use of the mobile app to unlock and lock bicycles. Your refusal to provide the necessary information for the execution of our rights and obligations under the contract may cause it not to be concluded or for its termination. The provision of the data for direct marketing purposes is completely voluntary and no adverse consequences will follow for you if you decide not to take advantage of this offer.

 

  1. Who do we share data with?

 

Streebl Ltd. protects the confidentiality of your personal information and does not disclose your personal data to third parties, except with your consent. In the case of guaranteed protection and security measures, disclosure is possible with our service providers in order to ensure the smooth functioning of the platform (e.g.with hosting providers, statistical analysis through Google Analytics, etc.)

 

Social networks

 

Our platform allows access to third-party social networks (e.g.Facebook, Instagram, Twitter, etc.). This allows the user to access our social networks through the use of personal data. These third parties can use cookies for their own purposes. STREEBL Ltd. has no influence on the way these social networks use. For more information about cookies set by social networks, please refer to their own privacy policies and cookies.

 

  1. How long do we store your data?

 

We store your personal data no longer than the necessary time to achieve the specific purposes for which it was collected, and then destroy it in a secure manner.

 

If you have agreed to have your data processed for direct marketing purposes, your data will be stored until withdrawal of consent or 3 years from the date of last entry into the system.

 

In case of an incomplete successful registration process, your completed data is deleted automatically.

 

In case of successful registration with right to use the bicycle stands, your data is stored for the following periods:

 

  • Data from your account – 3 years since your account was deactivated.If your account is inactive, the data is stored for 3 years from the date of the last entry into the system.

 

  • In the case of administrative or judicial proceedings initiated by or against customers, all data shall be stored for a period of 5 years after a final judgment or payment of the debt.

 

  1. Security measures

 

Your data is stored under technical and organizational measures that ensure their security, including the use of google cloud secure servers and cloud services in the European Union, encryption, technical, software and antivirus protection, protections for communication and computer networks, limited access to data only to authorized and trained employees, privacy policy and security procedures that we regularly review and revise as necessary etc.

 

  1. What are your rights?

 

You have certain rights in relation to your personal data, including:

 

  • Withdrawal of consent: You have the right to withdraw your consent at any time in case you have given one to process your data for a specific purpose, without prejudice to the processing to date. When you have given consent for direct marketing purposes, you can refuse to receive newsletters at any time by clicking on the “unsubscribe” link in the email messages or change your mobile app settings. If you have granted access to your location via the mobile device in order to find bike racks near you, you may also change the settings.
  • Access information: this right allows you toto obtain a copy of the personal data we hold about you, as well as information related to the processing. You can access the history of the services used by you and the data provided upon registration through your mobile app account, and you can also submit a special request for access to all data we process about you.
  • Correction: this right allows you to request from us to fix an inaccurate information about you. We ask you to always note any change in your personal data in your account in a timely manner or to notify us of this in the following e-mail.
  • Deletion: this right allows you to request from us to delete your personal data when we have no valid reason to continue processing them e.g. If the purpose for which the data were collected has been achieved or if you have withdrawn your consent. If the legal requirements are met, we will delete your personal data within 1 month, unless we have a legal obligation to continue processing them or the retention of the data is necessary for the establishment, exercise or protection of legal claims.
  • Objection to processing: in cases where we rely on our legitimate interests as a basis for processing, you may object to this processing on grounds related to your particular situation. You also have the right to object when the processing is for direct marketing purposes or your data is processed. If you wish not to receive any more marketing messages, you can click on the “unsubscribe” link and change your settings from the mobile app.
  • Restriction of processing: this right allows you to request from us to temporarily suspend the processing of your personal data if, for example, if you want us to check the accuracy of the data or the reasons for their processing.
  • Data portability: this right is limited to cases where the data is processed in an automated manner and provided to us by you on the basis of your consent or for the purposes of the performance of a contract, enabling you to require us to provide your data stored electronically to you or to a third party.
  • Right to complain – If you consider that any of your rights have been violated you have the right to lodge a complaint with us and/or to the supervisory authority Commission for Personal Data Protection – https://www.cpdp.bg/.

 

On matters related to this Privacy Notice or in case you wish to exercise any of the following rights as a data subject, you can contact us via e-mail: [email protected], tel. 359 878 95 95 66 or at:Sofia, 49 Chataldzha Str., 3, ap.7. When submitting requests for exercise of rights as an entity, please fill in and send us the following form. Upon such request by your party, we may need you to provide us with information confirming your identity. This requirement is our partial data protection measures and aims to ensure that personal information is not provided to a person who is not entitled to receive it.

 

  1. Liability when using bicycle stands

 

  • Streebl Ltd. is not responsible for stolen bicycle under any circumstances and/or actions by third parties;
  • “Streebl” Ltd. is not responsible for damaged bicycle when using the stand under any circumstances and/or actions of third parties;
  • “Streebl” Ltd. is not responsible in case of theft due to incorrect use of the stand;
  • When using the bike racks, you need to make sure that you have locked your bicycle correctly, following the instructions indicated on the dashboard of the stand and in the app; • “Streebl” Ltd. is not responsible when renting out your bicycle via the “Share bike” button to third parties (theft, damage, etc.).
  • “Streebl” Ltd. is not responsible for improper use of the stands by the third party.

 

Further information about Streebl Ltd. can be found on our web page: https://streebl.com/